G.R. No. 188352 ; September 1, 2010
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. ROLLY DE GUZMAN, Accused-Appellant.

FACTS

The accused-appellant, Rolly de Guzman, was charged with the rape of AAA, a 13-year-old minor, on October 29, 2006, in Quezon City. The prosecution evidence established that on the evening of the incident, the accused and a companion, Joel Sabado, invited AAA to a nearby construction site. Upon her refusal, Sabado pushed her inside the site gate. Threatened with harm, she was forced upstairs where de Guzman switched off the lights, forcibly undressed her, and had carnal knowledge with her despite her struggles. The following day, AAA reported the incident to her parents, leading to a barangay report and a medico-legal examination.
The medical examination revealed a “deep healed laceration” and a “shallow healed laceration” on AAA’s hymen, with a conclusion of “clear evidence of blunt penetrating trauma.” The accused denied the allegation, testifying that he was at the construction site barracks with co-workers when AAA’s parents arrived looking for her. He claimed no prior ill-feeling existed between them. The Regional Trial Court convicted de Guzman of rape, sentencing him to reclusion perpetua and ordering him to pay indemnity and moral damages. The Court of Appeals affirmed the conviction in toto.

ISSUE

Whether the Court of Appeals erred in affirming the conviction by giving undue credence to the testimony of the private complainant.

RULING

The Supreme Court denied the appeal and affirmed the conviction. The Court upheld the consistent findings of the trial court and the Court of Appeals, emphasizing that the assessment of the credibility of witnesses is best undertaken by the trial court. The testimony of AAA was found to be credible, straightforward, and consistent. The Court reiterated the doctrine that when a woman, especially a minor, testifies that she has been raped, she says all that is necessary to prove the commission of the crime, provided her testimony meets the test of credibility.
The medical findings corroborated AAA’s account, proving that sexual intercourse occurred. The defense of bare denial could not prevail over the positive and categorical identification by the victim. Denial, being inherently weak, must be supported by strong evidence of non-culpability, which was absent. The Court found no ill motive for AAA to falsely accuse the appellant, whom she knew as a neighbor. The elements of rape through force and intimidation were sufficiently proven: carnal knowledge was established by medical evidence, and the use of force was evident from the victim’s testimony of being pushed, threatened, and overpowered despite her resistance. The penalty of reclusion perpetua and the awards of civil indemnity and moral damages were affirmed as proper.